Pr. CIT vs. Bharat Sanchar Nigam Ltd (Delhi High Court)

S. 80IA(2A): As the words “derived from” are absent, there is no requirement to prove “first degree nexus” of the receipts with the eligible business. All receipts of the undertaking are eligible for 100% deduction

The legislature having ousted applicability of sub-section (1) and (2) in the opening sentence brought in for the purposes of time line sub-section (2) into play but made no efforts whatsoever to put the assessee under sub-section (2A) to meet the stringent requirements that the profits so contemplated were to be “derived from”. The requirements of the first degree nexus of the profits from the eligible business has not been brought into play

Pr. CIT vs. Bharat Sanchar Nigam Ltd (Delhi High Court)

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